FATCA.

What this module does

FATCA is the United States framework requiring foreign financial institutions to report accounts held by US persons. Depending on your jurisdiction’s intergovernmental agreement, the package goes either directly to the IRS through IDES, or to your local competent authority under a Model 1 agreement, which passes it on.

The module is the same engine as DAC2 and CRS, applying the FATCA XML schema instead. Nil reports and corrections are handled the same way as any other submission — as sessions.

The REGREP FATCA module takes your reportable account data as a spreadsheet, checks it against the structural and regulatory rules, tells you what is wrong with it, and produces the FATCA XML package for submission. It works in three stages, shown as three cards on one screen: data input, regulatory validation, and conversion to the submission format.

Before you start

The fields FATCA requires are:

Save the tab before leaving Settings.

Opening the module

Solutions → Regulatory Reporting → Tax Reporting Engine → FATCA.

Sessions

A FATCA session is one submission: a reporting year, a submission type, and the data that goes with it. Corrections to a submission you have already filed are handled as separate, linked sessions rather than by editing the original.

The list shows, for each session, its name, reporting year, report type, version, the parent session where one applies, the submission type, and when it was created and last opened. Two row actions are available: open the session, and delete it.

Creating a new submission

Use this for the first submission covering a given reporting year. Select + on the session list.

Select SAVE. You are taken to the file upload screen.

Correcting a submission you have already filed

If an error or omission is found in a submission that has already gone to the IRS or your competent authority, do not edit the original session. Create a correction session linked to it. The link preserves the audit trail and tells the receiving authority which report is being corrected.

Uploading your data

A newly created session opens on the upload screen. Drag a file onto the upload area, or select it to browse. Accepted format: .xlsx.

The sidebar on the left shows the session’s parameters — jurisdiction, creation timestamp, reporting year, submission type and version — so you can confirm you are loading data into the right session before you upload. Once the file is attached, REGREP begins processing immediately and the screen changes to the three processing cards.

Processing and validation

The three cards run in order. Each has to be satisfied before the next is meaningful: Data Input reports what was read from your file, Regulatory Validations reports what passes the FATCA rules, and XML Conversion builds the submission package.

Data Input

This card confirms the file was structurally readable and reports what it contained. A progress indicator runs during ingestion and is replaced by “Structural Validation Successful” when the file has been read.

UPLOAD NEW replaces the file with a revised one and re-runs the whole process.

Regulatory Validations

This card checks the ingested records against the FATCA reporting rules — formatting, structure and logical consistency.

Select DOWNLOAD ERRORS to export the error log. It lists each failing record and the reason it failed. Correct the records in your source data, return to the Data Input card and select UPLOAD NEW with the corrected file. Repeat until the error count is zero, or until every remaining error is one you have consciously accepted.

XML Conversion

The third card builds the submission package. The gauge shows conversion progress. Where the receiving authority expects one file per reportable jurisdiction, a Countries filter lets you produce a package for a single jurisdiction or for all of them at once; where it expects a single consolidated package, the filter is not shown.

A complete submission

1. Confirm Settings → Corporate Information is complete and saved, and that the LEI field validates.

2. Create the session: name, reporting year, the FATCA new-submission type, version 1.

3. Upload the reportable account data file (.xlsx).

4. Check the Data Input counts against your source system.

5. Review the Regulatory Validations card. Download the error log if there are errors.

6. Correct the source data and re-upload. Repeat until you are satisfied with the error count.

7. Have the submission reviewed by someone other than the preparer, using the Excel download.

8. Download the XML package and check the reporting institution details inside it.

9. Submit to the IRS, or your local competent authority under a Model 1 agreement through their own portal.

10. Record the submission reference against the session, and retain the session — a later correction will need it as its parent.

Handling personal data

FATCA files are unlike most of the data you load into REGREP. They contain named individuals, their addresses, their tax residences and their tax identification numbers, together with financial information about them. That is personal data under the GDPR.

• Upload only the data needed for the reporting obligation. Do not load a fuller extract because it was easier to produce.
• Treat the downloaded error log and the Excel summary the same way you treat the source file. They contain the same personal data, and they are the copies most likely to end up on a desktop or in an email.
• Keep downloaded packages in the location your firm has designated for regulated records, not in a personal downloads folder.
• Delete local working copies once the submission is filed and your retention copy is in place.
• Restrict access to the FATCA module to the people who need it. Access is controlled through Team Management.

Troubleshooting

Document control

REGREP is an independent software provider. This manual describes how to operate the platform and is not legal, tax or regulatory advice. Confirm scope, thresholds and submission dates with your competent authority before you file.